[IOT] Response to comments re proposed revisions to Rule 4

[Mike Rodenbaugh]

I can only make the first half-hour of the call today, if at all.  But i
want to object to Sec. G of this document which would only allow claimants
three business days to pay all fees to ICDR.  First, it is unclear what
those fees are currently, as neither ICANN nor ICDR has published any clear
info about it despite 'administering' the IRP for more than ten years
already.  Second, those fees are in the thousands of dollars currently
($3750 or $6250 or something else, depending on the claimant and the time
of their claim, apparently) -- which can be a lot of money for someone to
get to ICDR in three days, especially when they have no clue what the fee
will be when they file.  And third, whether *any* such fees are appropriate
is a question this Working Group (Initiation Subgroup) is now actively
considering, pending further promised info from ICANN Legal.

So Sec. G needs to be changed dramatically or deleted, in my view.

Thanks,
Mike

[image: Logo]

Mike Rodenbaugh

address:

548 Market Street, Box 55819

San Francisco, CA 94104

email:

mike at rodenbaugh.com

phone:

+1 (415) 738-8087


On Mon, Dec 13, 2021 at 5:12 PM Liz Le via IOT <iot at icann.org> wrote:

> Dear IOT members,
>
>
>
> Attached for the IOT’s consideration are some proposed revisions to the
> draft Rule 4 language that we circulated on 21 September 2021 based upon
> the feedback received from the IOT.  The revisions We look forward to
> discussing this with the IOT on tomorrow’s call.
>
>
>
> Best regards,
>
> Liz
>
>
>
> --
>
> Elizabeth Le
>
> Associate General Counsel | ICANN
>
> 12025 Waterfront Drive, Suite 300
>
> Los Angeles, CA 90094
>
>
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